Justia Wyoming Supreme Court Opinion Summaries

A man who founded a nonprofit community radio station in Wyoming contributed substantial sums of money to the station over several years. He claimed these were loans intended to support the station’s operations and expected repayment. Although he discussed loan terms with the station’s board and referenced a loan at a board meeting, no written agreement was ever executed, and he did not follow through on drafting a loan contract. Despite the lack of formal documentation, the station’s tax filings, prepared with his assistance, listed the contributions as loans, but other board members were not aware of or had not approved these filings until after he withdrew a significant amount as “repayment” and subsequently left the station.The District Court of Teton County reviewed the claims after the parties filed cross-motions for summary judgment. The plaintiff alleged breach of implied contract and unjust enrichment, asserting that the station’s tax filings and board members’ awareness supported his claims. The district court found no evidence of a written or oral agreement approved by the board, determined that the statute of frauds barred the implied contract claim, and granted summary judgment to the defendant. The court also found the unjust enrichment claim was barred by the statute of frauds.On appeal, the Supreme Court of Wyoming reviewed the district court’s judgment de novo. The Supreme Court affirmed the district court’s ruling that the breach of implied contract claim was barred by the statute of frauds, as no definite or certain terms existed to remove the agreement from the statute’s requirements. However, the Supreme Court clarified that Wyoming law does not bar unjust enrichment claims by the statute of frauds. Nevertheless, it held that the plaintiff failed to show the station was reasonably notified that repayment was expected, as required for unjust enrichment. The Supreme Court affirmed the district court’s grant of summary judgment for the defendant. View "Tallichet v. Jackson Hole Community Radio, Inc." on Justia Law

After successfully completing his probation nearly a decade earlier, the defendant began harassing his former probation officer through daily text messages, blaming him for personal misfortunes. The probation officer eventually blocked the defendant’s number, but the defendant later called 911 to make threats against him. Subsequently, the defendant appeared outside the probation office, made a threatening hand gesture, and sent numerous threatening text messages suggesting violence toward the officer and his family. These actions led to the probation office being locked down and evacuated, with staff sent home.The State charged the defendant with felony terroristic threats and misdemeanor stalking. The trial was held in the District Court of Uinta County, where a jury found the defendant guilty on both counts. The district court sentenced him to consecutive terms of confinement. On appeal, the defendant argued that the trial judge committed judicial misconduct during voir dire by making remarks to a prospective juror about bias in front of the jury panel, which he claimed undermined his right to a fair and impartial jury. He also challenged the sufficiency of the evidence supporting his terroristic threat conviction, specifically whether he acted in reckless disregard of the risk of causing evacuation.The Supreme Court of Wyoming reviewed the case. It held that the trial judge did not commit misconduct during voir dire; the judge appropriately inquired into the prospective juror’s bias and did not discourage candid responses by other jurors. The Court also found sufficient evidence to support the conviction for terroristic threats, concluding that the defendant’s conduct demonstrated reckless disregard for the risk of causing evacuation of the probation office. The Court affirmed the district court’s judgment and convictions. View "Pinegar v. The State of Wyoming" on Justia Law

The Wyoming legislature enacted the Steamboat Legacy Scholarship Act in 2025, creating an education savings account (ESA) program. This program allows parents of eligible Wyoming school-aged children to apply for up to $7,000 annually to fund education expenses outside the public school system. The ESAs are funded from a state general fund appropriation, not from local or school district taxes. Plaintiffs, including the Wyoming Education Association (WEA) and several individual parents, challenged the Act’s constitutionality, claiming it violated provisions of the Wyoming Constitution related to public education and state appropriations. The plaintiffs argued that the Act would harm their children, particularly those with disabilities, because private schools receiving ESA funds could deny admission or fail to provide needed services.The District Court of Laramie County granted a preliminary injunction, preventing implementation and funding of the ESA program while the lawsuit proceeded. The district court found that the plaintiffs were likely to succeed on the merits of their constitutional claims and that they would suffer irreparable injury if funds were distributed under the Act. The court reasoned that the Act likely violated constitutional limitations on appropriations for educational purposes to entities not under state control, and infringed upon the fundamental right to education by diverting funds from the public system.On appeal, the Supreme Court of Wyoming reviewed the district court’s decision for abuse of discretion. The Supreme Court held that the plaintiffs had not made a clear showing of possible irreparable, personal injury required for preliminary injunctive relief, as they did not intend to participate in the ESA program and their alleged harms were speculative. The court also questioned the district court’s legal analysis but did not decide the case on the merits. The Supreme Court of Wyoming reversed the preliminary injunction and remanded the case for further proceedings. View "Degenfelder v. Wyoming Education Association" on Justia Law

The defendant was involved in a violent incident with his girlfriend and their young daughter, during which he physically assaulted the girlfriend multiple times, including striking her with his fists and a handgun, strangling her to unconsciousness, and kicking her to the extent of causing severe injuries. Their daughter also sustained injuries. The defendant was charged with several felonies, including aggravated assault, battery, strangulation of a household member, and child abuse. He was also facing charges in other unrelated cases. The parties reached a global plea agreement covering all the charges, under which the defendant pled guilty to certain offenses, and the State agreed to dismiss others in exchange for restitution and the right for both sides to argue sentence.In the District Court of Goshen County, the defendant was sentenced to consecutive prison terms for the charges to which he pled guilty. At sentencing, the victim presented both oral and written impact statements, some of which referred to uncharged conduct by the defendant, including additional incidents of abuse and property theft or destruction. The defendant did not object to the use of these statements at sentencing.On appeal to the Supreme Court of the State of Wyoming, the defendant argued that the district court erred by considering the victim impact statements referencing uncharged crimes. The Wyoming Supreme Court applied the plain error standard, since no objection was raised below. The court held the defendant failed to show that the district court relied on inaccurate or unreliable information in imposing sentence; the record reflected the court’s decision relied on the violent nature of the charged offenses and the defendant’s criminal history, not on the contested statements. The court found no plain error or violation of due process, and affirmed the district court’s sentencing decision. View "Atkinson v. The State of Wyoming" on Justia Law

Richard Q. Navarro and his son-in-law, Antonio Oros-Garcia, jointly owned two vehicles, a 2011 Dodge RAM pickup and a 2017 Dodge Challenger, as joint tenants with rights of survivorship. Navarro paid the entirety of the loans used to finance the vehicles. Subsequently, Oros-Garcia became a fugitive and could not be found. Navarro, still in possession of the vehicles but unable to sell or transfer them due to the joint ownership, filed a lawsuit seeking a partition of the vehicles to resolve the ownership and allow him to act regarding the vehicles without interference.The District Court of Laramie County initially granted Navarro’s motion for entry of default after Oros-Garcia failed to respond. However, the court repeatedly requested a third-party valuation of the vehicles from Navarro to determine jurisdiction. When Navarro did not provide the specific valuation requested, the court dismissed the complaint on its own motion under W.R.C.P. 12(b)(6), concluding Wyoming’s partition statutes only applied to real property, not personal property, and suggested Navarro could seek relief through a replevin action.The Supreme Court of Wyoming reviewed the district court’s dismissal de novo and held that Wyoming law does not preclude partition of personal property merely because the statutes address only real property. The court found that, under common law, joint owners of personal property are entitled to seek partition, and the absence of a statute does not abrogate this right. Additionally, the court determined that partition actions are in rem or quasi in rem proceedings and fall within the jurisdiction of the district courts, not circuit courts, regardless of the property’s value. The Supreme Court of Wyoming reversed the district court’s dismissal and remanded for further proceedings. View "Navarro v. Oros-Garcia" on Justia Law

Brent Gayman and his wife, Rebecca, separated after forty-five years of marriage. Rebecca contacted law enforcement after leaving their home, reporting that Brent made abusive and threatening statements, including threats against family pets and sending angry messages to their daughter. After Rebecca returned to the home, Brent was observed repeatedly driving past the residence and was served with a protection order, which prohibited him from contacting Rebecca or being near her home or workplace. Despite this order, Brent continued to drive by the house, parked nearby, left annotated materials in a shared garage, surveilled the residence with binoculars, and left a typewritten suicide note on Rebecca’s car. These actions were reported to police, and Brent was arrested for stalking and violating the protection order.The State charged Brent with felony stalking and misdemeanor violation of a protection order in the District Court of Park County. At trial, the State presented testimony from Rebecca, her daughter, and her employer. Brent did not present any witnesses. After the State’s case, Brent moved for a judgment of acquittal, arguing insufficient evidence of intent to harass; the court denied this motion. The jury convicted Brent on both charges, and he was sentenced to prison.On appeal, Brent argued to the Supreme Court of Wyoming that the evidence was insufficient to prove he specifically intended to harass Rebecca or that his actions constituted a course of conduct reasonably likely to harass her in violation of the protection order. The Supreme Court of Wyoming held that there was sufficient evidence for a rational jury to find Brent acted with the specific intent to harass, based on both pre- and post-protection order conduct. The court affirmed the district court’s judgment. View "Gayman v. The State of Wyoming" on Justia Law

A law firm in Cheyenne, Wyoming, settled a personal injury case on a contingency fee basis. The dispute arose after a former associate attorney, who had assisted on the case, claimed he was owed additional compensation based on the hours he worked. Under his employment agreement, he initially received only a fixed salary, but later he was offered a quarterly bonus tied to receivables over a threshold. However, when the contingency case settled, the law firm’s recovery was not enough to provide bonus compensation to the associate after compensating the lead partner, in accordance with the firm’s established contingency fee distribution structure. As a result, the associate received no bonus credit for his hours on the case.The associate filed a wage claim with the Wyoming Department of Workforce Services, Labor Standards Division, arguing he was entitled to a bonus calculated at his usual hourly rate. The Department initially denied the claim. After a contested case hearing, the hearing examiner concluded the associate had not proven entitlement to the claimed wages, finding the bonus agreement did not cover contingency fee cases and that the firm’s contingency fee structure governed. The Laramie County District Court affirmed the Department’s denial.The Supreme Court of Wyoming reviewed the case, applying the substantial evidence standard to factual findings and abuse of discretion to evidentiary matters. The court held that substantial evidence supported the finding that the associate was not entitled to additional compensation for his work on the contingency fee case, as the bonus agreement was silent on such cases and the firm’s contingency fee structure applied. The court also found no abuse of discretion in the hearing examiner’s evidentiary rulings, including the admission of certain firm records and the limitation of discovery requests. The Supreme Court of Wyoming affirmed the lower court’s decision. View "Moncecchi v. Mckellar, Tiedeken & Scoggin, LLC" on Justia Law

A newborn child was taken into protective custody shortly after birth due to testing positive for methamphetamine and being abandoned by her mother at the hospital. The mother did not return, and the Department of Family Services (Department) was given custody. The child’s father was identified but was incarcerated at the time. Paternity was later confirmed. The Department developed a case plan for the father, which included requirements related to mental health, substance abuse, parenting, housing, and compliance with criminal proceedings. Because the father remained incarcerated, most aspects of his case plan could not be completed. He was able to participate in video visits and some treatment programs while in custody, but could not demonstrate sobriety or stability in the community.After the child was adjudicated neglected, the District Court of Natrona County initially ordered a permanency plan of reunification, contingent on successful completion of the case plan. Throughout the following year, the Department and multi-disciplinary team periodically reviewed the case. As months passed and the father’s release date remained uncertain, the Department recommended a concurrent plan of adoption. At a permanency hearing, evidence showed that, despite the father’s efforts within the limits of incarceration, reunification would require many more months, delaying stability for the child.The Supreme Court of Wyoming reviewed whether the district court abused its discretion by changing the permanency plan from reunification to adoption. The court held that the district court did not abuse its discretion. It found that sufficient evidence supported the conclusion that the child’s need for permanency and stability outweighed further delays inherent in waiting for the father to complete his case plan. The court affirmed the order changing the permanency plan to adoption, holding that adoption was in the child’s best interests. View "In the Interest Of: Ag, Minor Child v. The State of Wyoming" on Justia Law

A patient experienced severe complications following a routine appendectomy at a county hospital in Wyoming, leading to a diagnosis of short bowel syndrome. The surgery was performed by a hospital-employed physician. The following day, the patient suffered further abdominal issues and was transferred to another hospital, where emergency surgery resulted in substantial removal of her small intestine. The patient, initially a minor, sued the hospital and two of its physicians for medical malpractice, alleging their negligence under the Wyoming Governmental Claims Act. The hospital admitted the physicians were employees and that it was vicariously liable for their actions. As a defense, the hospital asserted that liability was limited by statute to $1 million.After these events, the District Court of Converse County denied the patient’s constitutional challenge to the statutory limitation, finding it was a limit on the waiver of immunity rather than damages. The case went to trial, where the jury awarded $8 million in total damages, with $3.2 million allocated against the hospital and the physician found liable. The court entered judgment for the full $3.2 million, despite the statutory limit. Motions for relief and further summary judgment followed, with the patient arguing the hospital’s operation of a statewide commercial healthcare enterprise should negate the statutory cap. The district court denied these motions, but clarified the hospital was not required to pay above the statutory limit.The Supreme Court of the State of Wyoming reviewed the case. It held the liability of the hospital and its physician is limited to $1 million under the Wyoming Governmental Claims Act, unless there is excess insurance coverage. The court found that operating a statewide commercial healthcare enterprise does not constitute a waiver of this statutory limitation. The judgment exceeding $1 million was reversed, and the case was remanded for entry of judgment consistent with the statutory cap. View "Memorial Hospital of Converse County v. Gates" on Justia Law

Following the parents’ divorce in 2012, ongoing custody disputes ensued over their two daughters. A 2019 order granted primary custody to the mother, with visitation for the father. In late 2024, the father filed for custody modification after the older daughter, then fifteen, reported that her mother had expelled her from the home. The father retrieved the daughter, took her to Colorado, and notified local police. Attempts at visitation and school enrollment led to further police involvement and contentious exchanges, including a physical altercation between the mother and daughter and additional conflicts involving the mother’s adult son. Throughout these events, the father sought temporary and then permanent changes to the custody order.The District Court of Laramie County initially addressed temporary custody motions and later held a hearing on the father’s petition for modification. The court appointed a guardian ad litem (GAL), who recommended counseling and ultimately a change in custody. At trial, both daughters expressed a preference for living with their mother. The GAL, however, recommended primary custody be transferred to the father. After weighing testimony and the GAL’s report, the district court found that a material change in circumstances had occurred, citing the breakdown of the mother’s relationship with the older daughter and ongoing instability. The court modified the order, awarding primary custody of both daughters to the father, with visitation for the mother.Upon review, the Supreme Court of Wyoming affirmed the district court’s decision. The court held that the district court did not abuse its discretion in finding a material change in circumstances or in concluding that awarding primary custody to the father was in the children’s best interests. The Supreme Court also granted the father costs, as permitted by rule, but not attorney’s fees, since he appeared pro se. View "Duncan v. Duncan" on Justia Law